आदेश/ORDER

PER GEORGE GEORGE K, VICE PRESIDENT:

This appeal at the instance of the assessee is directed against the final assessment order dated 06.12.2024, passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2018-19.

2. Brief facts of the case are as follows: The assessee is a company incorporated in UAE. During the assessment year 2018-19, the assessee was in receipt of income of Rs.90 lakhs from an Indian customer named M/s. Gannon Dunkerley and Company Ltd. It is stated that the payment was received for reviewing the existing design and drawing for a turnkey project of water supply distribution system at Jorhat, Assam. For the assessment year 2018-19, assessee did not file any return of income u/s.139 of the Act. According to the assessee, it did not have any Permanent Establishment (PE) in India and in absence of any income accruing or arising in India, t